Tax exemption for specified legal-services authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and...
Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
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Withholding certificates u/s 197 issued at lower rate tax - Respondents are required to pass an order u/s 197 either rejecting the application for such certificate or allowing such application resulting in issuance of certificates which may be at rates higher than nil rate sought for by the assessee, such an order must be supported by reasons. - In the instant case, we do not know the reasons for not granting nil rate certificates to the petitioner u/s 197 - The contemporaneous order required to be passed under section 197 of the Act is also not available - Matter restored back - HC
Withholding certificates u/s 197 issued at lower rate tax - Respondents are required to pass an order u/s 197 either rejecting the application for such certificate or allowing such application resulting in issuance of certificates which may be at rates higher than nil rate sought for by the assessee, such an order must be supported by reasons. - In the instant case, we do not know the reasons for not granting nil rate certificates to the petitioner u/s 197 - The contemporaneous order required to be passed under section 197 of the Act is also not available - Matter restored back - HC
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